JUDGMENT :

Vibhu Bakhru, J.

The petitioner has filed the present petition, inter alia, impugning an order-in-original dated 18.12.2020, passed by the Principal Commissioner of Customs (Preventive), New Delhi. The petitioner also impugns the constitutional validity of Sections 86, 87, 88, 94 & 97 of the Finance Act, 2022. In addition, the petitioner has also assailed the show cause notice dated 18.05.2018.

2. At the outset, the learned counsel appearing for the petitioner states that he confines the present petition to impugning the order-in-original dated 18.12.2020 and, in the alternative, praying for waiver of any pre-deposit under Section 129E of the Customs Act, 1962 (hereafter ‘the Customs Act’) for maintaining an appeal before the learned Customs, Excise and Service Tax Appellate Tribunal (hereafter ‘CESTAT’). He does not press any other relief.

3. In terms of the order-in-original, the Adjudicating Authority has imposed a penalty of Rs. 6,00,00,000/- under Section 112(b)(i) of the Customs Act.

4. The impugned order indicates that the officers of the Directorate of Revenue Int